ML20035C469
| ML20035C469 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/05/1993 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | CONNECTICUT YANKEE ATOMIC POWER CO. |
| Shared Package | |
| ML20035C467 | List: |
| References | |
| NUDOCS 9304080007 | |
| Download: ML20035C469 (5) | |
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UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION
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In the Matter of-
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NORTHEAST NUCLEAR ENERGY COMPANY
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Docket No._50-245 t
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(Millstone Unit 1)
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'I EXEMPTION I.
The Northeast Nuclear Energy Company (NNECO, the licensee) it the holder j
of Facility Operating License No. DPR-21 which authorizes operation of Millstone Nuclear Power Station, Unit 1.
The license provides, among other things, that Millstone Unit 1 is subject to all rules, regulations, and Orders of the Commission now or hereafter in effect.
The plant is a boiling water reactor located at the licensee's site in it i
New London County, Connecticut.
1 II.
One of the conditions of all operating licenses for water-cooled power reactors, as specified in 10 CFR 50.54(o), is that primary reactor I
containments shall meet the containment leakage test requirements set forth in 10 CFR Part 50, Appendix J.
More specifically the following sections require that:
10 CFR Part 50. Appendix J.Section III.D.2(a)
Type B tests,.except tests for air locks,.shall be performed during reactor shutdown for refueling, or other convenient intervals, but in no case at intervals greater than 2 years.
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. 1 10 CFR Part 50. Accendix J.Section III.D 3 Type C tests shall be performed during each reactor shutdown for i
refueling but in no case at intervals greater than 2 years.
By letter dated January 18, 1993, as supplemented by letter dated March 22,1993, NNEC0 requested schedular exemptions from the above requirements.
NNECO commenced the most recent local leak rate testing (LLRT) program at Millstone Unit 1 on April 7,1991, during the cycle 13 refueling outage. NNECO experienced an usually long refueling outage followed by a shutdown approximately 1 month after startup for licensed operator requalification.
This second outage was, in turn, extended due to erosion / corrosion inspections.
NNECO subsequently had another unplanned shutdown for service water system inspections and repair. Due to this series
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of circumstances, NNECO has postponed the refueling outage for cycle 14 from
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February 1993, to February 1994. The requirement to perform Type B and C LLRTs within a 2-year interval would require an unscheduled plant shutdown, given the current Millstone Unit I refueling outage schedule.
The total' schedular delay is expected to be approximately 10 months.
III.
By letter dated January 18, 1993, as supplemented by letter dated March 22, 1993, NNEC0 requested an exemption to the requirements of Section III.D.2(a) and III.D.3 which require that Type B and C testing be performed during each reactor shutdown for refueling but in no case at intervals greater than 2 years.
In their submittals and in a phone conference W. ween the staff j
and NNECO on March 16, 1993, NNEC0 stated that they were ur..ae to perform any of the LLRTs during the periods that the plant was shutdown due to the
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, i evolving nature of the unplanned shutdowns.
The outages were unplanned and t
were expected to be of short duration when they began. The outages evolved into much longer than anticipated durations as the scope of the work to be done became more apparent to NNEC0 management. The work performed during these outages was extensive causing NNECO to involve the majority of their resources.
This left them with insufficient resources to plan and perform the.
LLRT program at the same time, which among other things, would require many test procedures to be modified due to the fuel being in the reactor vessel.
NNECO performed a detailed analysis of the past leak rate history of the 98 penetrations in question. NNECO reviewed the results of their last six f
tests and found that of the 98 penetrations tested each time, a total of 18 different penetraticns had failed. The review showed that the majority of the penetrations were historically " good performers." NNECO has worked to improve the leak tightness of their containment penetrations. The success of these efforts is demonstrated by the f act that only two penetrations during the last six tests have had recurring failures. One (penctration X-14) was successfully fixed by NNECO in 1989, as is demonstrated by its passing the 1991 "as found" LLRT.
The other is penetration X-25/202D on which NNECO has committed to performing a mid-cycle test prior to the end of the 2-year test 1
interval.
NNECO has implemented a corrective action plan to address the problems with this penetration. The mid-cycle test of penetration X-25/2020 will demonstrate whether or not this corrective action plan has been successful.
NNECO also has further corrective actions scheduled for this penetration during the next refueling outage.
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, NNECO has committed to two compensatory measures in the interim until the refueling outage in order to demonstrate a good faith effort to comply with the regulations.
First, NNECO has identified 17 penetrations that they can reasonably test at power without placing the plant in inadvisable configurations or risking personnel safety. These 17 penetrations include 16 cable penetrations and the control rod drive hatch. These tests will be completed prior to the expiration of the 2-year test interval for each penetration.
In addition, NNECO will also test penetration X-25/2020 which has had recurring failures. This penetration will be tested in late April 1992.
NNEC0's second compensatory measure is to begin performing the LLRT program should they experience an unplanned outage of sufficient duration to begin testing penetrations.
NNECO has determined that an outage of 2 weeks or longer will be sufficient to begin testing. The number of penetrations that i
can be tested during the unplanned outage will depend on the length of the outage.
Based on the above evaluation, the staff finds there is reasonable assurance that the containment leakage-limiting function will be maintained and that a forced outage to perform Type B and C tests is not necessary.
Therefore, the staff finds the requested temporary exemption, to allow the Type B and C test intervals to be extended to the refueling outage which will begin no later than February 28, 1994, to be acceptable.
IV.
Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12(a), the requested exemption is authorized by law, will not present an
-5 undue risk to the public health and safety, and is consistent with the common defense and security.
Further, the Commission finds that_ the special circumstances required by 10 CFR 50.12(a)(2)(ii) and (v)-are present.
Application of the regulation in these particular circumstances is not necessary to achieve the underlying purpose of the rule in that, as discussed in Section III, the containment leakage-limiting function will be maintained and the exemption provides only temporary relief from the applicable regulation with which the licensee has made good faith efforts to comply by implementing an alternative program.
An exemption is hereby granted from the requiremer.ts of Sections III.D.2(a) and III.D.3 of Appendix J to 10 CFR Part 50, which require that i
Type B and C tests be performed during each reactor shutdown for refueling but in no case at intervals greater than 2 years, until the next refueling outage which is scheduled to begin no later than February 28, 1994.
Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this Exemption will have no significant impact on the quality of the human environment (58 FR 17627).
This Exemption is effective upo. issuance.
.OR THE NUCLEAR REGULATORY COMMISSION 7
Original signed by Steven A. Varga, Director Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Dated at Rockvilie, Maryland this 5thday of April 1993 a
- See previous concurrence 3
i OFFICE LA:PDI-4*
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AD:DRPE NAME SNorris JAndersen JStolz EHoller JCalvo %
DATE 3/29/93 3/29/93 3/29/93 3/31/93 4 / 5 /93 0FFICIAL RECORD COPY Document Name: G:\\ANDERSEN\\85483.EXP
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